Condition D of coastal development permit for the operation of SONGS Units 2 & 3 requires the permittee (SCE) to fund scientific and support staff retained by the California Coastal Commission to oversee the site assessments, project design and implementation, and monitoring activities for the mitigation projects designed to compensate for the past and ongoing adverse effects of SONGS operations on coastal marine resources.

Implementation Structure

Scientific expertise is provided to the Commission by a small technical oversight team hired under contract. Currently, the technical oversight team members include three Principal Scientists from UC Santa Barbara: Daniel Reed, Ph.D., kelp forest ecologist, , Mark Page, Ph.D., wetlands ecologist , and Stephen Schroeter, Ph.D., marine ecologist. A search is currently underway to add two Assistant Research Biologists to the team in 2022. In addition, a science advisory panel advises the Commission on the design, implementation, monitoring, and remediation of the mitigation projects. Current science advisory panel members include Dr. Richard Ambrose, Professor, UCLA, Dr. Peter Raimondi, Professor, UC Santa Cruz, and Dr. Russell Schmitt, Professor, UC Santa Barbara.

To meet the goals specified in the permit under Condition D and to complete the tasks identified in the 2022-2023 work program, the technical oversight team is aided by contract staff biologists who are responsible for collecting and assembling the monitoring data. The technical oversight team is also assisted on occasion by independent consultants and subcontractors when expertise for specific tasks is needed or when additional field assistance is needed for monitoring tasks. The Commission’s permanent staff also spends a portion of their time on this program, but except for direct travel reimbursements, their costs are paid by the Commission and are not included in the SONGS budget.

The staff implements the Commission’s technical oversight and independent monitoring program through a contract with the University of California, Santa Barbara. UCSB has an international reputation for excellence in ecology and marine biology and is well equipped to support extramural contracts and grants in these areas. The UCSB contract uses the existing Principal Scientists as project managers for both the wetland restoration and reef mitigation oversight and independent monitoring, with data collection and management done by the university staff biologists under their direction. The Principal Scientists are responsible for supervising the UCSB staff biologists, subcontractors and consultants, authorizing purchases, interacting with UC administrative staff on issues pertaining to personnel, budget, off campus lease space and UC policies (e.g., boating and diving safety regulations) relevant to the project, and interacting with CCC staff assigned to the mitigation efforts. Monitoring of these projects is being adaptively managed in order to streamline effort and minimize costs without compromising the integrity of the data and their value in decision making with regards to the performance of the mitigation projects. Continuous interaction between the Principal Scientists and contract staff biologists is crucial to fulfilling the monitoring tasks for both the wetland restoration and mitigation reef.

Before starting the five-year Phase I Experimental Reef monitoring program in 1999, staff conducted a cost comparison among UCSB, other universities, and private consultants and concluded that use of a qualified university would save SCE a substantial sum over the use of private consultants. Based on 1995 real cost data from private consultants for work that included the same physical and biological variables used in the SONGS reef monitoring program, costs for private consultants were nearly three times higher than the cost of implementing the monitoring program through UCSB.

The Commission concurred with staff at the start of the monitoring program and continues to find that implementing the field monitoring programs through a contract with UCSB is the most efficient, cost-effective, scientifically rigorous, and timely method of achieving the goals of the independent monitoring required by the SONGS permit.